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unstable, were you not, as that year progressed?

A. I would not say "unstable."

Q. In fact, you threatened to kill your boss ######## ######## at the Lyons Recorder; did you not?

A. No, sir. I've never threatened to kill anyone.

Q. I've heard you say that, Mr. Wolf, repeatedly.

A. Yes, and you will again, I imagine.

Q. That was -- you were fired by ######## ########--

A. Yes.

Q. -- only a few weeks before the murder of JonBenét Ramsey; were you not, sir?

A. I think it was much longer a period of time before that murder than that. I think it was a couple, a few months before that.

Q. Before the murder of JonBenét Ramsey, had you ever expressed the view that Lockheed Martin exported weapons?

A. I imagine I -- I don't know about

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specifically Lockheed. I don't think I had any particular pet defense contractor that I was, you know, on a bandwagon against. I think that, you know, Lockheed is one of a well-known handful of big defense contractors that make us the number one arms exporter in the country by far. And I was aware of that fact, and I have expressed that view.

Q. In the world.

A. In the world.

Q. And had you expressed the view before the murder of JonBenét Ramsey that Lockheed Martin was responsible for killing children all over the world?

A. I think my previous answer is sufficient. I think that the weapons that this country exports all over the world have killed many children, and I think that that's, you know, somewhat outrageous. I think that, obviously, we -- there are political struggles and disputes, and, you know, that thing does and will continue to happen. But I just hate to see people so willing to fan the flames of those problems.

Q. You had that view before the

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murder of JonBenét Ramsey; did you not, sir?

A. Yes, I certainly did.

Q. Mr. Wolf, your adoptive mother, #######, is blonde; is she not?

A. No, she's not blonde. She is brunette, and now she's sort of got frosted hair.

Q. She was a beauty pageant winner; was she not, sir?

A. She was a Home Coming Queen.

Q. When was that?

A. When she was in high school. She never was in a beauty pageant.

Q. And did you have a strong dislike, or do you have a strong dislike for your adoptive mother?

A. No, I don't have a strong dislike for her at all. I have a -- I have a somewhat of a difficult relationship with her that I've always tried to deal with as positively and constructively as I could.

Q. Have you ever owned a weapon?
A. No, sir.

Q. A gun?

A. No, sir.

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Q. A knife?

A. Well, a BB gun. And a Swiss Army knife.

Q. A stun gun?

A. No, sir.

Q. Have you ever used a firearm?

A. It's not my thing. I don't --

Q. Just tell me yes or no, please.

A. When the guns come out in the movies, I leave. I don't -- I'm not interested. I've never seen Speed. I don't see those kind of movies. I'm not interested in violence.

Q. Have you used a gun, sir?

A. No -- well, a BB gun. And, you know, I guess I -- I guess I shot a handgun once back when I was 20 at a friend of mine's farm. He had a-- he had an old, kind of a -- sort of a vintage firearm, and we fired it a couple -- once or twice. And I think that may have been the last time I fired a gun.

Q. Have you ever used a stun gun?

A. No, sir.

Q. Have you ever had one in your

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A. No, sir.

Q. Mr. Wolf, have you ever been a cross-dresser?

A. No, I wouldn't say that.

Q. Have you ever dressed in woman's underwear?

A. On Halloween I wore a dress.

Q. Have you ever dressed in woman's underwear?

A. No.

Q. Which Halloween did you wear a dress?

A. Last Halloween.

Q. Do you, from time to time, shave your legs?

A. Yes, sir.

Q. How long have you been doing that?

A. Since I was racing bicycles. And I don't do it on any regular basis at all. I've done it probably six times in my life. Mostly when I was bike racing, which I did that for three years.

Q. Do you dial what I will refer to as pornographic telephone lines?

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A. I have.

Q. While you were living with Jackie Dilson, did you do that?

A. Yes, sir. I regret to say that I did. I realize that that was not the right thing to do when you live with a woman.

Q. Do you frequent what I refer to as porn shops?

A. Yes, sir. I have been to them on a number of occasions over many years.

Q. This is true throughout the '90s and before?

A. Uh-huh (affirmative).

Q. Did you tell Ricky Elsey that you enjoy staring at school girls?

A. No, sir.

Q. Did you own a pair of Hi-Tec boots? And I want to get the spelling correct, H-i, dash, capital T-e-c.

A. No, sir. I never owned a pair of Hi-Tec boots. I own a pair of Danner boots that Jackie bought me.

Q. If Jackie Dilson or Ricky Elsey or anyone else said that you had owned a pair of Hi-Tec boots, they were simply mistaken or

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lying; is that correct?

A. They were lying because -- yeah, simply mistaken or lying, yes.

Q. Well, I said mistaken or lying, but in fact, your answer began with they were lying; didn't it, sir?

A. Well, Jackie knew what kind of boots that I wore. So if Jackie said they were Hi-Tec boots -- Jackie bought those boots for me, so I -- I don't know. I guess she wouldn't know one brand for another, so she could be mistaken. But I've got those boots in Kentucky, and I can produce them for you at any time you want.

Q. Did you borrow a long, black metal flashlight from Jackie Dilson's home?

A. No, sir.

Q. Ever?

A. I didn't know that -- I didn't know her to have one, and I have not borrowed one for any purpose.

Q. Did the police ever even show you one?

A. I don't think so.

Q. You were a rock climber at one

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time; were you not, sir?

A. Yes, sir.

Q. You became very familiar with knots during your rock climbing; did you not?

A. Climbing knots.

Q. Yes, sir.

A. Well, and it was definitely my weak point as a climber. Knots and the mechanics.

Q. In your bathroom at Jackie Dilson's home, could Ricky Elsey have found five pairs of little girls underwear?

A. I didn't have a bathroom that was my bathroom. Jackie and I shared the bathrooms. And I guess he could have found -- I mean, Jackie had lots of people over, and, you know, the place was a bed and breakfast, and a conference center, and there were children there. And for all I know -- I mean, everything else that he has apparently said to you has been a lie, so I assume that that may be, too, although he may have found five pairs of children's underwear in the bathroom.

Q. Let me put the question to you

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this way. Did you bring little girls' underwear into the Dilson home, sir?

A. No, sir.

Q. Have you ever --

A. No, sir.

Q. -- collected little girl's underwear --

A. No, sir.

Q. -- of the size that might be worn by a four, five, or six-year-old girl?

A. No, sir.

Q. And if, after your truck stopped to open a gate, in the plain view of Ricky Elsey and Jackie Dilson, and very soon thereafter, a little pair of little girl's underwear was found right where it might have fallen out of your automobile or truck, it didn't get there from your vehicle?

A. Well, I didn't own a truck. Jackie owned a truck. And if Jackie had little girls' underwear in the car and it fell out when I opened the door, that may have happened, but I don't have anything to do with any little girl's underwear.

Q. With Jackie Dilson, did you ever

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engage in a fantasy that she was a six-year-old girl?

A. No, sir.

Q. Did you ever put your hands around her neck and squeeze her neck?

A. I have put my hands around her neck. I have never squeezed her neck.

Q. When did you put your hands around her neck?

A. I did that as sort of a joke because she had told me that she has fantasies of being killed during having sex, which I thought was strange, and I didn't want to participate in any play, in any playing around like that with her, but I -- at one point, as I recall, as I have been reminded by people who reminded me about that incident in regards to this case, I think I do recall one time trying to -- going in to wake her up and in so doing, putting my hands gently, without any pressure that would cause even the slightest bit of injury, around her neck sort of as a joke, which sort of came to me just as the spur of the moment. And I-- you know, relating to her

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having told me that she has a fantasy of being murdered during sex. So I, you know, I don't know anything about S&M or violence or anything like that, and I never played any of that, anything like that with her or anyone else, but I did do that sort of kind of stupid thing at one point, as I recall.

Q. Did you tell Jackie Dilson soon after JonBenét Ramsey was murdered that you would never strangle anyone with your hands; you would always use a rope?

A. No, sir. No. I never said anything like that.

Q. That seems funny to you; didn't it?

A. It's so, so ridiculously out of character for me to even discuss things like that. I'm not interested in violence. I'm certainly not interested in harming a child.

Q. Your personal possessions, Mr. Wolf, when you lived with Jackie Dilson included clippings of news stories about JonBenét Ramsey; didn't they, sir?

A. No, sir, absolutely not.

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Q. It also included clippings of news accounts about the murder of Susanna Chase; didn't they?

A. I kept one story about Susanna Chase. It was the story in the Boulder Planet because it was such a nice picture of her. And -- and I did know her, and I knew her because she was a clerk at a grocery store that I went to often. And she was a wonderful, beautiful, young woman who I found, you know, charming and delightful to, you know, chat with in the process of going through the line. And would certainly never, ever want any harm to come to a person like that or really anyone. That's not even considering the idea that I -- well, you haven't suggested that I harmed her, and that's fine.

Q. Yes, it's unnecessary for you to deny that, Mr. Wolf. You once lived in an apartment near 19th Street and Pearl, did you not, in Boulder?

A. Uh-huh (affirmative).

Q. How far was that from the site of

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her --

A. It wasn't -- it was 20th and -- 20th and Pine.

Q. Okay. How far was that, approximately, from the site where her body, Susanna Chase's body was found?

A. I think it was just a few blocks. It was diagonal about -- it was south about a block and a half, and then west about two blocks or so. I don't know where, exactly where her body was found, but I know the general area, and it was a -- it was terrible shock to me to have heard about that.

MR. RAWLS: Mr. Gallo, would you please mark this as the next Defendant's exhibit, please. Is that 4? (Defendant's Exhibit-4 was marked for identification.)

MR. RAWLS: This is a blank sheet of paper that I marked as Defendant's Exhibit 4, and because it's blank, Evan, you probably have no interest in seeing it, and I have no real need to show it to Darnay.

MR. ALTMAN: No objection.

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Q. (By Mr. Rawls) Mr. Wolf, may I hand you Exhibit 4, and may I also ask you to please take a pen or pencil of your choice from the table here. Would you write several words for me, please, in your own hand? "John." (Witness complies with request of counsel.)

Q. "Ramsey." (Witness complies with request of counsel.)

Q. "Police." (Witness complies with request of counsel.)

Q. The phrase "grow a brain." (Witness complies with request of counsel.)

Q. The word "connotation." (Witness complies with request of counsel.)

Q. The word "possessed." (Witness complies with request of counsel.)

Q. Thank you. I appreciate you

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complying with that request. May I see that, please?

A. Still trying to frame me.

Q. Mr. Wolf, you may accuse anyone that you care to accuse. And I have no doubt, given your testimony today, that you will do that.

MR. RAWLS: Will you please keep this with the original exhibits, Mr. Gallo?

Q. (By Mr. Rawls) What does "SBTC" mean to you, sir?

A. Nothing.

Q. Did you ever have a sweat shirt or a T-shirt with those letters on it?

A. No.

Q. Do you have some familiarity with Santa Barbara?

A. I've never been there.

Q. Have you ever had a T-shirt or sweat shirt with the name Santa Barbara on it?

A. Jackie's son gave me a T-shirt with the name Santa Barbara on it.

Q. Was there any other language on that T-shirt?

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A. Not that I recall.

Q. Do you still own that T-shirt?

A. No, sir.

Q. Do you still own a blue sweater that, according to Jackie Dilson, you were wearing on December 26, 1996?

A. I remember that sweater, and I don't have that sweater anymore. I haven't for some time. It was a rag when, at that time, I think.

Q. Where is that sweater?

A. I have no idea. It's been garbaged a long time ago.

Q. Have you regularly taken any medication during the 1990s --

A. No, sir.

Q. -- up through today?

A. No, sir.

MR. RAWLS: Let me suggest we take five or six minutes. And I want to confer with my colleagues, look at my notes, and gather a few exhibits, and then we'll come back and see if we can conclude after a few more minutes. Thank you.

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THE VIDEOGRAPHER: We are off the video record at 5:49. (A recess was taken.)

THE VIDEOGRAPHER: We are on the video record at 6:04.

Q. (By Mr. Rawls) Mr. Wolf, who trained you in your use of knots?

A. Oh, friends that taught me climbing and -- yeah, mostly friends who taught me climbing.

Q. Who?

A. I don't know. People I don't remember their names now, a long, long time ago.

Q. What knots were you taught?

A. Figure 8, overhand knot, a bowline.

Q. A slipknot?

A. I don't call a bowline a slipknot.

Q. No. Were you taught a slipknot?

A. No. That's not a climbing knot.

Q. What other knots were you taught?

A. Those are the main ones. The only other one that I'm thinking of, and I don't recall what it's called is a -- is a

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knot that links two strands of rope together end to end, and it is just a figure 8 that you follow through from -- with the other end. Those are the only knots I know besides a bow and a square knot.

Q. Is that a sheepshank?

A. That could be. I don't really want to say that for sure. I don't know that that's what that's called.

Q. When in your life did you do rock climbing?

A. Age 20. Maybe 20 -- probably 20 through -- I don't know. Let's see. I guess, yeah, I guess, 21 or 22 through 30. Not continuously, but --

Q. Did you do any rock climbing after age 30?

A. No. Nope. I pretty much quit.

Q. Tell me, sir, your e-mail addresses for the last five years.

A. I only have ever had one, and that is ############

Q. Is that still --

A. Yes.

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Q. -- your e-mail address?

A. Uh-huh (affirmative).

Q. Have you taken part in internet forums?

A. No.

Q. Chat groups?

A. No.

Q. Any internet exchanges concerning JonBenét Ramsey?

A. No.

Q. Or the murder investigation of JonBenét Ramsey?

A. Well, I corresponded by e-mail to Mr. Wood last week just to correct him on a false -- an inaccurate quote that he said about me in the Westword.

Q. Any other use of the internet concerning JonBenét Ramsey by you?

A. I check the Boulder Camera for stories occasionally. And this has only been -- I guess it's been, maybe -- maybe a year that I've been doing this at all. And over the past year it's been very sporadically that I've done it at all. But over the past year, I have

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looked at Mrs. Brady occasionally, and Boulder Daily Camera, and, oh, some of those others that are listed under Ramsey, but no chat rooms, or I've never sent any responses or anything like that to any questions or polls or comments, or anything like that. I've just tried to keep up on -- I've just looked at it to keep up on anything resembling news that has happened just in the last year, and not prior to that.

Q. Mr. Wolf, when you worked as a stripper with a variety of agencies, as you told us about earlier in this deposition, did you ever, from time to time, dance at a strip club?
A. I have danced at a couple of strip clubs, just sort of like applying for a job or trying to get a job working at these clubs in New Orleans. And I didn't really want to continue working at any of those places.

Q. Did you get turned down at any of those places?

A. Oh, I guess you'd say that, yeah, but it was -- the feeling was mutual, and

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that was probably why. Although --

Q. So on occasion, you got turned down as a dancer at strip clubs and decided after you were turned down that you didn't really like the club anyway. Is that what you are --

A. You could say that if you want.

Q. Well, is it true, Mr. Wolf?

A. It's true in the reverse order, too. I didn't like them, so why would they like me?

Q. Well, who spoke first about the liking or disliking, Mr. Wolf? Were you told first that you were not going to be hired, or did you say, first, that you did not care to apply?

A. Oh, I can't recall.

Q. Mr. Wolf, did you ever see the movie Dirty Harry?

A. Yeah, I saw that movie. Yeah. I think I may have probably fell asleep. I don't remember anything about it.

Q. Did you see the movie Ransom?

A. No, sir.

Q. Did you ever see the movie Speed?

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A. No, sir. Never heard of it -- never heard of Ransom or Speed except for in regards to this case.

Q. When did you see the movie Dirty Harry?

A. I guess when it was -- came out or soon thereafter in the '70s. I don't like those kind of movies. And, I mean, when you're that -- when you're a kid, you know, you end up going to things that you don't know whether you want to be there or not sometimes. And I didn't like it then, and I haven't made a point of seeing those kinds of movies as I have gotten older.

Q. How many of the sequels to Dirty Harry did you see?

A. None.

Q. Can you tell me their names?

A. No, sir. I never heard of them. I didn't know there were any.

Q. Have you in the last ten years used illegal drugs?

A. Yes, sir.

Q. What drugs?

A. Marijuana.

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Q. Any other drugs?

A. Ecstacy.

Q. Any other drugs?

A. No.

Q. How regularly did you use marijuana?

A. Regularly, until a few -- a couple of years ago. I'd say, oh, often, a few times a week.

Q. You were a regular marijuana user in 1995, 1996, and 1997?

A. Yes, sir.

Q. How frequently did you use Ecstacy?

A. I have only done that three times in my life.

Q. When?

A. This past fall.

Q. All three times this past fall?

A. Yes, three out of four weekends.

Q. Never before the murder of JonBenét Ramsey?

A. Never before the murder of JonBenét Ramsey.

Q. Have you ever been arrested for

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drug use?

A. No, sir.

Q. For drug possession?

A. No, sir.

Q. For drug dealing?

A. No, sir.

Q. Have you ever sold illegal drugs?

A. No, sir.

Q. Have you ever been arrested for drunkenness?

A. No, sir -- well, yeah. I was in Dallas, I think I told you about. I -- but like I said, I mean, I was taken in handcuffs and put in the drunk tank, but I did not receive paper or court date. I never did anything more on it. So I figured I was not arrested. I mean, if you want to -- if you call that arrest, I don't know. I mean, it worked fine for me. I was probably a danger to myself being that intoxicated. I was about 22. And I was drunk as I've ever been, and I ended up in the drunk tank for the night. It was basically like a -- it wasn't a police station. It was a Salvation Army drunk tank

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or something. I don't know what. But they just let me out the next day, and I went home and never did anything more about it.

Q. How many times have you been, in the last ten years, have you been so drunk as to be a danger to yourself?

A. Well, oh, I don't know. A few, I guess. I mean, I never hurt myself. I never had a car accident when I was drunk, so I shouldn't say I was probably a danger to myself. I've never injured myself drinking, and I've never injured anyone else drinking, as a result of drinking. So -- so I don't think I was a danger to myself that night. I was just very, very drunk, and I guess they didn't appreciate it, the police.

Q. Mr. --

A. And as far as in the last ten years, I was very drunk over Mardi Gras in 1999, when I lived in New Orleans; but other than that, I haven't gotten that drunk for, like, I don't know, 15 years since I consumed that much alcohol. I had a few beers to watch a baseball game is all, except for Mardi Gras, in the last 15 years.

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Q. Why did you not consult an attorney given your concern that you have outlined for us today about the Lawrence Schiller book?

A. Given my concern about the Lawrence Schiller book? What concern?

Q. Why didn't you consult an attorney about a possible action involving Mr. Schiller's book on your behalf?

A. Because I thought that that was basically accurate, and I thought that he said that I had been cleared as a suspect.

Q. Mr. Wolf, you told us very early today that your paternal grandparents with whom you are living currently do not know about this case, and you do not want them to know about this case.

A. That's right.

Q. Why do you not want them to know about this case?

A. I think for obvious reasons.

Q. This is a case in which you are trying to uphold your reputation; is it not, sir?

A. You could say that.

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Q. Aren't you proud of this case?

A. I would say I'm more likely trying to -- oh, well, okay, yes. I'm trying to uphold my reputation. I'm trying to right a wrong that was done to me. And so in that sense, yes, I'm, I guess -- I wouldn't say proud. It's not a kind of situation that anybody probably particularly would like to be associated with, but I guess I'm committed to trying to get justice for myself regarding this case.

Q. Are you or are you not proud of your lawsuit?

A. I don't think I'm proud or not proud. I don't think that that is an applicable word. I'm just doing what I feel like has to be done.

Q. Have you visited internet pornography sites?

A. No, sir.

Q. Ever?

A. I have seen them over someone's shoulder once.

Q. Where? Whose shoulder was that?

A. Some person in New Orleans.

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Q. Was this at one of your performances?

A. No.

Q. Who was the person in New Orleans, please?

A. It was a person that I knew who was a gay man who was attracted to me and who I went to his house to ask him if I could borrow money.

Q. Do you recall his name?

A. No, I don't.

Q. Where do you access the internet from at present?

A. From the Lexington Public Library.

Q. And in the past, where have you gotten access to the internet?

A. Boulder County Public Library.

Q. Where else?

A. That's all.

Q. In connection with your first conversation with Darnay Hoffman, who initiated the contact, you or Mr. Hoffman?

A. I don't recall.

Q. At that time, were you aware that Darnay Hoffman had filed a lawsuit in his own

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name against the Ramseys arising out of the publication of the book The Death of Innocence?

A. I was aware that he was a vocal critic of the Ramseys and the investigation and the Boulder authorities, but I don't think that I was specifically aware that he had filed a lawsuit.

Q. Are you aware of that now?

A. I've read that.

Q. Before today?

A. Before today.

Q. Mr. Wolf, earlier today -- and this was on page 245 -- excuse me, 244 and 245 of your deposition. I'd like to read you a couple of questions and answers to remind you what you testified. I asked, "Did you ever put your hands around her neck and squeeze her neck?" We were referring to Jackie Dilson. Your answer was, "I have put my hands around her neck. I have never squeezed her neck." That was your answer. I then asked you, "When did you put your hands around her neck?" You spoke

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of you did that as sort of a joke. You spoke about her having fantasies of being killed during sex --

A. I told you she had told me that she had those. I did not know that she had those.

Q. Absolutely. And I don't mean to be, by paraphrasing, I don't mean to be changing this record at all, and I'm not -- I don't have the power to do that. And believe me, I do not wish to do that. But I did want to get to the part of your answer I wanted to ask you about. And that was the following: Quote: At one point, as I recall, as I have been reminded by people who reminded me about that incident with regard to, say, this case, I think I do recall one time trying to, going in to wake her up. Do you recall that testimony that I just quoted?

A. Yes, I do.

Q. All right. Who were the people who reminded you about that incident?

A. I can't really remember. I was

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trying to think of the answer to that question at that time I was talking about it, and I guess I just -- I guess it was somebody in Boulder who was sort of a kind of a little -- sort of -- I don't know. Either a reporter or a, sort of just some sort of, a kind of a Ramsey -- Ramsey investigation groupee or something. But I guess it must have been a reporter; although, I don't know. It could have been some -- just some other sort of little groupee kind of person.

Q. No name comes to mind right now?

A. I don't recall who may have been telling me about that.

Q. What, Mr. Wolf, have you done to prepare for this deposition?

A. I've thought about my reasons for filing this lawsuit, and I read the number -- some of the books, looked at some of the -- looked at mostly Steve Thomas' book. And I have just tried to prepare myself for you all to slander and intimidate me like you have been doing.

Q. Mr. Wolf, thank you for that.

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A. Sure.

Q. I appreciate that.

A. Well, sir, when you ask me to write six words that you are going to, apparently, get some bogus handwriting analysis to say that they look like that ransom note, what do you expect me to say?

Q. Thank you again, Mr. Wolf. And please don't volunteer testimony that is not an answer to my question. All right? It's getting late in the day. I know you're exhausted.

A. I'm fine.

Q. I am tired.

A. What good is six words?

MR. ALTMAN: Just answer the question. THE WITNESS: All right.

Q. (By Mr. Rawls) Mr. Wolf, what else did you do in preparation for this deposition?

A. I thought through a lot of what I have been doing at different points along the line, at different points in this case, and what I have been thinking or doing, or where

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I had been. I thought about dates and itinerary as far as moving here, there, which jobs I had when, who I talked to when, which reporters I talked to in sequence at what time. And I thought of all -- I thought of all the reasons why I'm here to tell you how wrong this whole thing has been regarding me. And for no fault of my own. For only the -- for only the fault of the wealth and power of the Ramseys who have bought the district attorney's office.

Q. Did the Ramseys ever buy Jackie Dilson?

A. I imagine they probably did.

Q. Mr. Wolf --

A. And if they didn't, they certainly did appropriate her.

Q. Apart from the argument and speeches you wish to make, have you otherwise answered my question?

A. Yes, sir.

Q. And finished?

A. Yes, sir.

Q. Now, Mr. Wolf, what other

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documents did you read that you have not told me about yet in preparation for this deposition?

A. I don't think -- I didn't even read -- I read the -- I read a few chapters of the Steve Thomas' book, and -- because I started that book back maybe a year or more ago. I read about maybe a -- not quite a third of it. I really don't like reading those kind of books. It's very literal writing. I'm just bored by it, and I couldn't really keep up and hang with it. So I stopped about maybe close to a third of the way through. And then I, in the last few days, prior to this deposition, I picked it up and read another 50 to 60 pages over two days. And as far as anything else I have read, Darnay asked me to read the complaint, and I could not find my copy of the complaint because I have moved. And I just have -- that's all. I don't think I've read anything else.

Q. How long did you spend talking with your attorneys in preparation for this

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A. Oh, Darnay and I have talked frequently, sometimes more than others, and certainly in the last week or so or couple weeks leading up to this, we've talked pretty frequently. I don't know. Is this attorney-client privilege at all?

Q. The question is, How long? I don't care what you said.

A. How many hours all together?

Q. Yes, sir.

A. Over what, two weeks, over the last two weeks?

Q. In preparation for this deposition.

A. In preparation -- in preparation for this deposition, well, I don't know. Maybe an hour. And, basically, all he's told me is I just need to be honest. And I don't -- he has not told me anything particular or specific to say or not say. He's just -- he's basically, as he's done a lot of the time over the year or more than year that he's been handling this case for me, he's tried to calm me down and make me feel somewhat, you know, kind of

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less --

Q. Mr. Wolf. I'm am sure Mr. Hoffman --

A. -- less worried about it.

Q. -- is a true humanitarian and is very interested in the search for the truth here, but I do not want to know what he told you. Just how long, sir, and you've answered that. You said about an hour.

A. Okay.

Q. All right? And I will stipulate that you made no attempt to waive the attorney-client privilege in the self-serving argument that you just made to me about in the conversations that you and Mr. Hoffman have had. All right?

A. Sure.

Q. Mr. Wolf, which investigators in the Boulder Police Department have given you evidence?

A. None.

Q. Have given you information about the investigation into the death of JonBenét Ramsey?

A. I wouldn't call anything that I

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have been told information.

Q. Earlier today, and this was at page 70, line 8, of your deposition, you referred to a person with whom you lived for a short period of time who was a friend of yours before and since. And then you said, "although she is dead." Who is that person?

A. Yeah. I remember both of those people. R#######

Q. How did she die?

A. She died in a bicycling accident.

Q. When?

A. Ah, must be -- must be a couple of years ago now. Maybe it is two years this summer. It might be three years this summer. I bet it's three years this summer.

Q. Was it a collision with an automobile?

A. No. As I understand it, what I have been told is that she hit a rock going down a steep hill, flew off her bike, hit her head, and died pretty much on the scene.

Q. Mr. Wolf, at page 172 of your deposition today, you testified -- and this

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I'm going to read, beginning at line 8, actually line 7: "He said, Listen to me, you are not a suspect." And this was Tom Whitman.

A. Uh-huh (affirmative).

Q. Quoting you again, "So that was the third time I had heard that from the police, and, of course, that was nice to hear, but, nonetheless, I knew it wasn't the end of my problems with this." The first question I want to ask you is, what were the other two times?

A. The first time was with -- was a week after I had initially been pulled in when John Eller told me, We have no interest in you in this case. The second time was when Carey Weinheimer told me, What are you worried about? You don't have anything to worry about.

Q. Did she tell you why?

A. That's a he.

Q. Did he tell you why?

A. No, she wasn't more specific. So you might construe that as not being told I

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was cleared, but I did at that time.

Q. Those were the two times?

A. Those were the two times prior to Tom Wickman telling me, You are not a suspect. And then Michael Kane saying, You don't have anything to worry about. Being a material witness in a grand jury investigation is different than being a target.

Q. And, Mr. Wolf, the other question I have for you about that previous testimony which I just read to you is, why did you know that was not going to be the end of your problems?

A. Well, because I knew that they were just taking all the evidence in, and, for all I knew, I was still being set up to be framed. For all I know, I still am. I mean, at that point -- the first time I refused to cooperate with the police, a few weeks after the murder, I was naive enough to think that it would be resolved. And since I didn't have anything to do with it, and that I would be -- I wouldn't have -- I really half-expected or maybe probably three-quarters expected not to

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hear from them anymore at that time. And so by the time Carey Weinheimer asked me to come in, I was aware that it wasn't going to end at that point for me.

Q. What was not going to end, sir?

A. The problems. The stress, the worry, the burden.

Q. Did you bring more of those problems on yourself by filing this lawsuit, sir?

A. The way I see it, sir, is that when the parents of the murdered child published a book specifying me as someone who they thought could be or was possibly responsible for such a crime as that, and then went on national television and, for whatever reason, were able to get my picture posted on national TV on the Today Show, and say things like, We're still investigating him, we have a lot of unanswered questions, he represents a lot of unanswered questions still; at that point, I felt like it was certainly a case of lesser of -- a worse of two choices, whether to file a lawsuit or not

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file a lawsuit. But I decided that I did not want the Ramseys or anyone else to think for a minute that I could or would ever do such a thing as that. Because that's really important to me, as you might understand, as you might think it might be important to you if someone were trying to suggest to the rest of the world that you were the kind of person that could do something like that.

Q. Mr. Wolf, if you're finished with your speech --

A. I'm answering your question.

Q. -- let me ask you to answer my question yes or no. Did you bring any of those problems on yourself by filing this lawsuit?

A. I'm trying to solve those problems by filing this lawsuit.

MR. RAWLS: Would you, please, Mr. Gallo, mark this as Defendant's Exhibit 5. Evan, here's a copy. (Defendant's Exhibit-5 was marked for identification.)

Q. (By Mr. Rawls) Mr. Wolf, the

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document you've just been handed by Mr. Gallo is Defendant's Exhibit 5. It purports to be a copy of a letter to you from November 7, 1989. Would you take a moment and see if you recognize that letter, please.

A. Yes, I guess I do recognize this. This is -- this is -- this never came to pass at all.

Q. The letter did come to you; did it?

A. I do recall this. And this is really, I think -- I think I was -- I wonder how in the hell you got a copy of this letter.

Q. Well, I don't doubt that, Mr. Wolf, given your testimony.

A. You guys must have your ways. Well, I never saw Bill McReynolds as academic advisor. This never happened.

Q. You were advised in writing that your academic advisor would be Bill McReynolds; were you not, sir?

A. And now I'm trying to wonder what you might be trying to prove as a result of suggesting that I -- that Bill McReynolds was

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my academic advisor. What would that mean to you?

Q. Mr. Wolf, would you please do your wondering --

MR. ALTMAN: Just answer the question.

Q. (By Mr. Rawls) -- when you're not required to answer my question because you'll have a lot of time to wonder about that, but could you just answer the question?

A. What question?

Q. You received this letter; did you not, sir?

A. Yes, I did. I think I recall receiving this letter.

Q. And it told you that your academic advisor would be Bill McReynolds; did it not, sir?

A. Yes.

Q. So you can understand a certain amount of surprise on our part when we heard your testimony earlier today, could you not, sir?

A. Well --

Q. But that doesn't matter, and I'll

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withdraw the question.

A. -- it doesn't matter because he was never my academic advisor for any, any significant period of time or for any portion of my time in school. I, in fact, I -- my academic advisor at that point, for whatever reason, and I can't recall why it was changed, but my academic advisor was Frank Kaplan. And he was my first academic advisor. And then that did change later, but Bill McReynolds never did serve as my academic advisor. I mean, so I guess you can't imply that me and Bill McReynolds sat in his office in the university in the journalism school and discussed whatever you might imagine.

Q. Mr. Wolf, there's no question pending, but are you finished --

A. Yes, sir.

Q. -- with your remarks --

A. Yes, sir.

Q. -- about Mr. McReynolds? Thank you. You know you have filed a lawsuit

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for libel; do you not, sir?

A. Yes, sir.

Q. And you know you filed a lawsuit in which you claim that Patsy Ramsey murdered her daughter; do you not, sir?

A. Yes, sir.

Q. Do you understand that, when a plaintiff files a libel lawsuit, that plaintiff puts his character in issue?

A. Yes, sir.

Q. Do you understand that?

A. Yes, sir, I understand that.

Q. And that plaintiff puts his reputation in issue. Do you understand that?

A. Yes, sir, I understand that.

Q. Do you understand that you have put your reputation in issue by filing this lawsuit?

A. I understand that now, and I understood that at the time that I decided to file this lawsuit.

Q. And you understood that you have placed your character in issue; did you not, sir?

A. Yes, sir.

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Q. And you understood that it was my duty to ask you questions about matters about your private life that I wish I never knew about. Did you understand that?

A. Sure.

Q. Do you know, Mr. Wolf, that I've never in my life in a legal profession or in my private life asked someone about their masturbation practices, and I wish I didn't have to do that today; do you recognize that?

A. Yeah, and I imagine that some of the attorneys involved in this case never asked people about how a six-year-old child was murdered, brutally tortured and murdered either, and had vaginal trauma either. And nobody has asked me about any of those things.

Q. Mr. Wolf, you're going to get your day in court, Mr. Wolf, in this case. Today it was our job to try to learn some information about Chris Wolf, his character, his reputation, and his conduct, and I compliment you for having sat through that today, and I appreciate your having done that.

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Q. Chris, could you just clarify one thing for me just briefly? I will try to keep it short. You were asked earlier as to whether or not you were shunned by specific individuals. I believe that was one of the questions. Do you know if that was a complete answer that you gave?

A. I had also recalled a time more recently when I was walking down the street near my house in -- on the hill in Boulder, and a couple of cops came walking up toward me, and I didn't know either one of them. I don't know if I'd either really seen either one of them very often, but one of them said to me, as we passed, kind of over his shoulder, You better stop with that sex something or another, something about sex.

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You better, something about sex, or something. And I turned around and I looked, and he was looking at me, and I go, What? And he goes, You're a sex offender; aren't you? And I said, Well, certainly not. And he said, Well, that's good, I guess, or something like that. And I don't know. There was a little more to it, I think. He said, You're a sex offender; aren't you? And I said, Well, you know, I don't know. I don't really keep track of your lists that you post, or whatever you do with them, but -- but I've certainly never had sex with a child, is what I told him. And he said, Well, that's good, and then they walked away.

Q. Do you remember anything else?

A. Ah, well --

Q. If you don't, just say you don't.

A. I guess not off the top of my head.

Q. I have another question for you. At one point in your deposition, you were asked as to the disposition of the so-called indecent exposure, and I believe your answer was that there was $125 fine and

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13 hours of community service. Is that correct?

A. Yes.

Q. Could you please explain precisely what that community service was?

A. I went on two different occasions, that I recall -- though it may have been three, but I believe it was two occasions, I think it was two weekends in a row, to cut the lawn with a push -- gas-powered push mower of an old lady in Littleton.

Q. Do you know who made that assignment?

A. I think it was some female probation officer, or whatever you would call that officer that does those things. Community service officer or -- maybe she wasn't. Probably wasn't even a police officer. But I think she was in civilian -- I'm sure she was in civilian clothes.

Q. Do you know whether or not that parole officer or person that assigned you actually had read your file before you were assigned to an old lady?

A. She had it in front of her when

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we were talking.

Q. So you assumed, then, that she actually knew the nature of your crime before she assigned you to a little old lady; is that correct?

A. Yeah, I assume that she knew what -- I have no doubt that she knew what I was being -- that what I was serving community service for.

Q. Do you know if the little old lady that you cut the lawn for knew whether or not you were there because of some offense, some community service that you were performing?

A. I don't know what she may or may not have known. I don't know what she may or may not have known.

MR. HOFFMAN: All right. That's it for me.

MR. RAWLS: I have got -- Evan, did you have a question?

MR. ALTMAN: Why don't you ask yours. It is just a follow-up.

MR. RAWLS: Oh, please go right ahead.

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MR. ALTMAN: The only question I have, Jim, is, I just want to know if we can get a copy of that exhibit, that handwriting exhibit that we can take with us?

MR. RAWLS: Certainly.

MR. ALTMAN: Okay. That's it. Thank you.


Q. Mr. Wolf, the incident you spoke about with your remarks by the police officer, what jogged your memory about that? Did one of your attorneys jog your memory about that incident during a break?

A. Darnay asked me what --

Q. I don't want to know what he asked you. I want to know if he jogged your memory about that during a break.

A. He asked me to be more specific about those matters, those issues.

Q. Did he jog your memory about that incident during a break?

A. He jogged my memory to remember everything I could, and that's one of the other things that I remembered.

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Q. And I have got just one other follow-up question. On your computer, what is your password?

A. I can't -- I have to tell you my password? What's a password for? On my computer or my e-mail?

Q. Both.

A. I don't have a password on my computer, and why would I tell you my password on my e-mail?

Q. To help us access it.

A. That doesn't seem like something that is appropriate for you to ask me for.

Q. Well, you can provide it or you can decide not to, and we can move the judge to compel, and you can feel free to take a few moments.

A. I'll tell you. You are welcome. Please look at it right now before I go anywhere. Please. Look at it. Let's look at it. Can we look at it, please?

Q. Mr. Wolf, I'm not going to do that, sir. You can tell me or not.

A. Can we make an agreement for them

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to call it up right now?

MR. RAWLS: Absolutely not.

MR. ALTMAN: No, not right now.

MR. WOLF: Why can't we do that?

MR. ALTMAN: Let's do this. Are you willing to give it or not?

THE WITNESS: Yeah. I want to give it, but I want to give it on the stipulation that we look at it right now.

Q. (By Mr. Rawls) Just give it to me.

A. It's "##############"


MR. RAWLS: Thanks. I have no further questions.

MR. ALTMAN: No further questions.


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Wolf deposition part 5

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